Documentary Evidence of Nuclear Pollution

While radiological protection is internationally recognised, within this discussion it is officially recognised that cardiovascular and other radiation related illnesses and morbidity are not incorporated in ICRP risk models for purposes of radiological protection.

This request for further documentation is not to do with radiological protection,but specifically the recognised risks the ICRP risk model excludes and the CERRIE uncertainties of ICRP dose model and outcome of research CERRIE recommended. That the Department Of Health recognises these considerations and they have been incorporated into documented current strategic planning and funding for communities hosting nuclear facilities and it’s recognised increases in ill health/morbidity through recognised paths of exposure.

“This document originates in a recommendation by Sir Frank Layfield, in his report of the Sizewell B Public lnquiry (1986) that the Health and Safety Executive (HSE) should ‘formulate and publish guidelines on the tolerable levels of individual and social risk to workers and the public from nuclear power stations.’” “He recommended ‘that as a first step, HSE should publish a document on the basis of which public, expert and Parliamentary opinion could be expressed.’” INTRODUCTION PARAGRAPH 1 PAGE 1“

It seems right however, at a time when no such proposals are in immediate prospect, to bring up to date the thinking that has applied so far, and to republish, in the Tolerability document, the overall approach and standards which the Health and Safety Commission and HSE intend should apply, whatever changes may in future be made in the approach described in the SAPs.” INTRODUCTION 7 PARAGRAPH 1

“ So this document, like its predecessor, is a straightforward account written for the general public.” “It is written in a spirit that final judgements about whether a given risk is tolerable are not matters for experts alone, but for the people who have to bear the risks, and who are therefore entitled to be given the best possible technical advice about them.”INTRODUCTION PARAGRAPH 9 PAGE 2

”A considerable part is played by consultation with representatives of all parties including the people at risk. In this way, the best presently attainable regulatory standards are determined.” GENERAL PRINCIPLES OF REGULATION PARAGRAPH 40 PAGE 10

“ What could happen is that, depending on the size of the doses, a proportion of the people receiving them would develop a cancer some years after the exposure took place or possibly pass on a genetic abnormality to some of their descendants “” So, by and large, the risk that an individual experiences from radiation exposure is to increase somewhat that person’s chance later in life of developing a cancer, which might or might not be treatable.” INDIVIDUAL RISKPARAGRAPH 60 PAGE 13

For example at coastal sites there is some probability that the wind would take the substance out to sea; or the substance might be in such a form that it would not be carried far, or might be deposited in larger concentrations in particular places. INDIVIDUAL RISK PARAGRAPH 58 PAGE 13

“we have to bear in mind that a very large nuclear accident, say approaching the size of Chernobyl, would have long term economic effects, eg in rendering land and buildings sterile, and this has to be taken into account in any estimation, however rough and ready, of total detriment.”LEVELS OF SOCIETAL RISK PARAGRAPH 183 PAGE 32

“This was the approach adopted in the 1988 version of this document, which concluded that an overall risk of one considerable accident per 10 000 years from any one of a programme of modern reactors would be just tolerable.”LEVELS OF SOCIETAL RISK PARAGRAPH 188 PAGE 33

“For the late deaths, the risk is spread very unevenly over several decades and the attributable death is unlikely to occur until ages in the region of 60 to 80 years.” APPENDIX PARAGRAPH 4 PAGE 35

If the radiation exposure is spread over a lifetime, or occurs in mid-life, the typical period of life lost due to an attributable death is about 15 years. For early effects, or early deaths from other causes, such as accidents, the period lost is typically about 35 years. Ignoring this difference over-emphasises the importance of the deaths attributable to radiation. APPENDIX PARAGRAPH 5 PAGE 35

“The results of the environmental monitoring programme for 2011 are also reported here, together with an assessment of the maximum likely radiation dose to the general public resulting from the combined operations at both sites.” INTRODUCTION PARAGRAPH 2 PAGE 7

“The Hinkley Point A site annual discharge limit for ‘other’ activity is 700 GBq.‘Other’ activity predominantly comprises strontium 90 (in association with its short-lived daughter product yttrium 90) but also includes smaller amounts of radionuclides such as plutonium 241 and americium 241. Strontium 90 is a fission product and decays by emission of beta particle and has a half-life of approximately 28 years. Plutonium 241 and americium 241 have half-lives of approximately 14 and 458 years, respectively. OTHER ACTIVITY A SITE LIQUID EFFLUENT DISCHARGES PARAGRAPH 2 PAGE 10

“The Hinkley Point B power station annual discharge limit for ‘radionuclides other than tritium, sulphur-35, cobalt-60 and caesium-137’ is now 80 Gbq. “ PARAGRAPH 2 PAGE 19

“All gaseous effluent discharges are filtered, hence the low level of particulate activity shown above.The levels of activity are normally very small and will vary little under normal operating conditions.

The main discharge points are:

(a) Contaminated ventilation systems, which discharge ventilation air from many places around each reactor and from the central block. This route is also used for minor carbon dioxide discharges from the reactors to adjust reactor pressures or purity of the gas coolant.

(b) The Reactor Blowdown Stack used for major discharges of carbon dioxide by reactor depressurisation. “ PAGE 26

Milk “The individual samples are prepared each quarter (Inner Farm) and are sent to the Contracted Analytical Laboratory at Sellafield” PARAGRAPH 1 PAGE 48

Name of the operator and to what international standards? how dose rates are considered in light of CERRIE recommendations?

The RIFE Report is produced annually by the following government organisations: Environment Agency, the Food Standards Agency, the Northern Ireland Environment Agency and the Scottish Environment Protection Agency. The report is produced independently of site operators. All reports are available via the respective internet sites for the organisations. “ PARAGRAPH 1 Page 51

The Hinkley Point Site Stakeholder Group document does not have radioactive inventory accounting and there is an absence of mathematical margin of error when dealing with exposure doses or indication to which standard the dose model has been calculated. We assume ICRP dose model and ask for Clarification on when CERRIE report recommendations and research will be incorporated to cover full illness doses other than ICRP protection model that has limited health scope and focuses almost completely on cancer only. Omission of aerial emissions wind and rain dispersion patterns and liquid emissions distributed by tidal flow- these are required so acceptable uniform exposure can be calculated . There appears to be no high volume air monitoring as recommended by CERRIE, yet HPA-CRCE-041 Environmental Radioactivity Surveillance Programme Included air monitoring following the Fukushima Dai-ichi Accident in Japan and the Centre for Ecology and Hydrology published on small amounts of fallout from Fukushima over uk available via their information gateway!What are the other radionuclide emissions and why when they are listed for Hinkley A are they not listed for Hinkley B ?

Rife 16 Radioactivity in Food and Environment (CEFAS) Does not seem to incorporate CERRIE recommendations and focuses only on ICRP methodology. Where is reasoning of adequacy of monitoring in relation to reactor de-pressurisation events and the verification these do not create spikes in average emissions and localised dose increases? Deposition on grass and crops is discussed and it would be expected to have a mathematical model and explanation to accurately reflect total environmental loading and accounting of where exactly the rest of the released inventory has gone.

”Internal emitters are radioactive substances taken into the body, mainly by ingestion and inhalation. It has been recognised for some time that the uncertainties associated with the risks of internal emitters are often significantly greater than those associated with external sources of radiation .The Department of Health has had this question under review for a number of years and has sponsored much relevant research.“ PARAGRAPH 2 PAGE 1

Accordingly, in 2001, the Government requested the Committee on Medical Aspects of Radiation in the Environment (COMARE) to provide up-to-date advice on the risk estimates applied to radiation arising from radioactivity within the body. Consequently, on 31 July 2001, the then Environment Minister, Rt Hon Michael Meacher MP, after consulting COMARE, announced that a working group would be set up with the following remit, “to consider present risk models for radiation and health that apply to exposure to radiation from internal radionuclides in the light of recent studies and to identify any further research that may be needed.” PARAGRAPH 7 PAGE 2

Breathing in radioactive particles in air or eating food and water contaminated with radionuclides. Intakes may also occur through wounds and skin abrasions. NOTE 1 PAGE 6

” The ICRP cites risks for fatal cancer and includes added element for non-fatal cancers and genetic effects. Non-cancer effects from radiation, such as cardiovascular effects, are not included, “NOTE 4 PAGE 8

Doses calculated by the above models do not result in a single value but a range of possible values, often illustrated by a bell-shaped or similar-shaped distribution curve. Current ICRP dose coefficients 5 are expressed as a single value (usually the ‘most probable’ value, ie the high point in the distribution curve). In many cases, the range of values can be wide. Uncertainty in these models is often defined as the ratio of the 95th to the 5th percentile values in the curve: this is the definition used in this Report.

Recent studies have attempted to quantify uncertainties using probabilistic techniques,and some studies (eg Goossens et al, 1997; NCRP, 1997) have estimated that the uncertainties in the organ dose coefficients of some radionuclides can be very large. PARAGRAPH 17 PAGE 9

With internal emitters, more uncertainties need to be added to those affecting external radiation. These arise from the assumptions made in deriving doses from internal radionuclides using biokinetic and dosimetric models and from the RBEs used for internal radionuclides. A key issue is the correctness of using risks derived from external, acute, large doses of high energy gamma and neutron radiation from the A-bomb blasts to derive the risks for internal, low level, chronic exposures to alpha and beta emitters. In a general sense, the Committee was concerned that reliable estimates

of uncertainties were required for the many steps and parts of steps used to estimate dose coefficients of internal emitters. A number of members were also concerned that published analyses of uncertainties in dose coefficients showed large ranges for some radionuclides. Although the Committee did not attempt to quantify uncertainties in dose coefficients, it was noted that ranges for equivalent doses to organs and tissues may vary from factors of two to three above and below the central estimate for radionuclides for which good data were available to well over a factor of ten for other radionuclides. These uncertainties are additional to those applying to risk estimates. PARAGRAPH 19 PAGE 10

Uncertainties in risk estimates and variability both have implications for the reliability of risk estimates used in radiological protection, particularly in the regulation of practices that result in exposures to radiation. PARAGRAPH 20 PAGE 10

“ Risk estimates (see section 2.3) for radiation-induced cancers are derived mainly from studies of the effects of external irradiation, the principal source of information being follow-up studies of the Japanese A-bomb survivors.” These comparisons apply to a number of radiation-induced cancers – leukaemia,bone, liver and lung cancer. However, for a number of cancer types, including colon,stomach, bladder and breast cancer, no reliable information is available on quantitative risks from internal emitters with which to check the validity of applying risk estimates for exposure to external radiation.” PARAGRAPH 5 PAGE 12

“The ICRP has not published information on uncertainties in dose coefficients” “Indeed, the actual concepts of absorbed dose become questionable, and sometimes meaningless, when considering interactions at the cellular and molecular levels.”“ the Committee was generally agreed that advances in understanding in microdosimetry would be likely to improve the scientific basis for radiation risk assessment and that this would be a beneficial development. Research in this area should be promoted.” PARAGRAPH 11 PAGE 13

The ICRP uses broad judgements to smooth over many of the experimental differences in RBE by the use of generic radiation weighting factors (wR), to which a value of 20 is assigned for all high LET alpha particle irradiation, and 1 for all low LET radiations (ICRP, 1991). It is clear that this is a broad-brush simplification for radiological protection purposes. In a rigorous scientific sense, this procedure would not be regarded as acceptable. PARAGRAPH 21 PAGE 16

Committee members expressed varying degrees of dissatisfaction with the ICRP dosimetric models. For longer-range radiations, the consensus was that the dosimetric models are generally satisfactory. However, the spatial resolution of biokinetic and dosimetric models may not be high enough to take account of the heterogeneous distribution of very short-range charged particle emissions (eg alpha emitters, low energy beta emitters such as tritium, and Auger emitters) in relation to target cells and sub- cellular structures, and most importantly those ionisation events which may specifically affect the cell nucleus and its DNA. This problem may, in specific instances, be a major underlying cause of uncertainty, and possibly error, in dose calculations for internal emitters. Members differed in the extent of the perceived problem but agreed that this area should be identified as one in which more research effort is needed. A thorough understanding of microdosimetry would appear to be an essential pre-requisite. The Committee recommends that steps be taken to fund and support appropriate research. PARAGRAPH 42 PAGE 23

effective dose when applied to different radionuclides singly or in combination, as the interpretation of a single, whole-body quantity is bound to be ambiguous. PARAGRAPH 49 PAGE 24

A primary source of uncertainty is the chemical form of the radionuclide inhaled or ingested (Harrison et al, 2001). The ICRP dose coefficients are based on generic assumptions regarding inhaled particle sizes and the solubility of radionuclides in the respiratory and alimentary tracts. Specific information may be available on the chemical form of the intake. It would be inappropriate, for example, to use the generic model for ingested 137Cs if the intake was known to be in an insoluble particulate form. Default assumptions regarding solubility in the respiratory tract can and should be substituted by specific information when the intake is of known chemical form. Further research is needed to extend the information base available in this area. PARAGRAPH 56 PAGE 25

“Shortage of detailed experimental data, especially from humans, is a major factor in the uncertainties associated with biokinetic models.” PARAGRAPH 57 PAGE 27

“The ICRP has chosen not to address uncertainties in dose coefficients specifically in its publications.” PARAGRAPH 64 PAGE 28

Committee members agreed that the assessment of uncertainties in dose and risk estimates was important. There were differences, however, between members on the circumstances where uncertainties should be used in radiological protection. Some members considered that an explicit declaration of likely uncertainties should, wherever possible, form part of all dose and risk estimations. They remained concerned that the failure to consider uncertainties could lead to unsound scientific conclusions and policy decisions. PARAGRAPH 6 PAGE 28

“The Committee further concluded that it was important that the scientific basis of the ICRP methodology should continue to be challenged, and that developments in microdosimetry and radiobiology should inform judgements on their reliability.” PARAGRAPH 69 PAGE 30

Committee members agreed that insufficient attention has been paid in the past to uncertainties in dose and risk estimates for internal emitters. Reliable quantitative estimates of uncertainties in dose coefficients for a range of radionuclides are not yet available. PARAGRAPH 72 PAGE 30-31

The Committee considered the problem posed by Auger emitters, noting that current ICRP methodology takes no account of the increased RBE of DNA-bound Auger emitters. PARAGRAPH 1 PAGE 39

Committee members were agreed that the possibility of increased risk from Auger emitters on the basis of cellular location and non-uniform distribution between cells within tissues should be examined for individual radionuclides and chemical forms of concern. This would involve experimental studies of distribution, together with studies of biological effects for those radionuclides/chemical forms showing significant presence in cell nuclei. The ICRP recognises these uncertainties for Auger emitters and has stated in ICRP Publication 92 (2003) that they represent a special case and will need continued special attention. PARAGRAPH 7 PAGE 40

“the Committee recognised that current recommendations from the ICRP that were formulated in 1990 pre-dated much of the biological information discussed in this chapter. The Committee endorsed ongoing national and international radiobiology research programmes particularly in respect of microdosimetry, induced genomic instability, bystander effects, cancer mechanisms and germline minisatellite mutagenesis.” PARAGRAPH 44 PAGE 53

There was general agreement that whilst much has been learnt from studying the responses of individual cells irradiated in vitro, studying isolated cells cannot reveal the complexity of tissue responses in which complex cell–cell interactions and micro-environmental factors contribute to the overall in vivo response. Complex tissue responses may be of particular relevance to the effects of certain inhaled or ingested radioactive particles that become non-uniformly distributed in tissue and give rise to local doses which are high compared with the same amount of energy averaged over the whole body or organ. Accordingly, the Committee recommends that research effort be put into whole-tissue radiation responses. PARAGRAPH 46 PAGE 54

Epidemiological Evidence cancer mortality. For people exposed at age 50 years, the lifetime risks may be similar for non-cancer and for solid cancer mortality (ie around 3–4% at 1 Sv) (Preston et al, 2003). Whether a risk of these non-cancer effects exists at low doses will depend on the biological mechanisms of their induction by radiation, which have yet to be determined. PARAGRAPH 64 PAGE 78

The Committee considers that a valuable complement to epidemiological studies of those exposed to internal emitters is the measurement of the presence (and levels) of radionuclides in study subjects through appropriate bioassay techniques. This is becoming increasingly common in studies of workers, a trend that is to be encouraged, but has not often been carried out in studies of those environmentally exposed. Such bioassay measurements would provide an important aid to the interpretation of epidemiological studies, and many of these methods (such as the measurement of radionuclides in urine or in teeth removed for orthodontic purposes) are not invasive and could be carried out relatively easily. The possibility of such bioassay measurements being made on appropriate samples from members of the public resident in various parts of the country, to determine general levels of radionuclides around, and distant from, nuclear sites should also be considered. The Committee recommends that greater use be made of presently available bioassay techniques. PARAGRAPH 77 PAGE 80

A related and complementary issue is the possibility of performing biodosimetry measurements on study subjects. Certain measures of biological damage (such as chromosomal aberration rates in peripheral blood lymphocytes) have been developed which can be related to the dose received by the relevant cells. However, this is not straightforward for internal emitters such as plutonium since the dose may not be delivered to the cells that are the basis of the assay. Further, such techniques usually involve the sampling of blood, which could present ethical difficulties under certain

circumstances. Nonetheless, biodosimetry has proved to be of value in specific instances, and the Committee recommends that the suitability of techniques for measuring biological damage related to clinical effects be monitored to assess whether they can be applied to epidemiological studies of internal emitters. PARAGRAPH 78 PAGE 80

2 The Committee noted that uncertainties in dose coefficients for some radionuclides are large and recommended that more work should be undertaken to quantify uncertainties for a range of internal emitters and to identify the major sources of these uncertainties. Information on uncertainties would inform judgements on the reliability of dose estimates and would also help identify research priorities which should then receive attention. Members encouraged COMARE to foster such analyses of uncertainties. PARAGRAPH 2 PAGE 119

Further to item (b) above, the Committee recommends further measurements of radioactivity levels in air, soil and other materials in coastal, estuarine and inland areas, to establish whether significant differences exist between these areas.

In addition, the Committee is aware that the COMARE study of the geographical distribution of childhood cancer cases in Britain, particularly near nuclear sites, is nearing completion. When this study is finished, the results should be reviewed to determine whether they justify a broader study of adult cancers near nuclear sites and contaminated estuaries. PARAGRAPH 10 PAGE 121

The Committee considers that bioassay techniques, to measure levels of radionuclides in study subjects, provide a valuable complement to epidemiological studies of those exposed to internal emitters. The Committee recommends that greater use be made of presently available bioassay techniques and that, in specific instances, the suitability of biodosimetry measurements on study subjects be assessed. PARAGRAGH 11 PAGE 121

Centre for Ecology and Hydrology “Post-Chernobyl soil and vegetation surveys (1986-1987) – map of sample locations” –documents high levels of contamination from Ceasium 137 in Benbicula and North Wales, it is also publicly recognised that the sheep on hill farms were removed from food chain. On the basis of these recognised facts please provide information regarding further studies and scientific reports documenting Cancer and Cardiovascular diseases based on the recommendations of the CERRIE report recognising inadequacies in ICRP risk model.